U.S. Department of Transportation

Federal Railroad Administration

 Kelso-Martin’s Bluff Improvement 

Projects

Task 5 and Task 6

 FINDING OF NO SIGNIFICANT IMPACT

and

Section 4(f) de minimis Determination
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

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Contents

1.0 INTRODUCTION.................................................................................................................................4

2.0 PURPOSE AND NEED..........................................................................................................................5

3.0 DESCRIPTIONOF ALTERNATIVES.......................................................................................................5

3.1 No Build Alternative......................................................................................................................6

3.2 Build Alternative ...........................................................................................................................6

3.3 MAPS.............................................................................................................................................6

Figure 1: Task 5 Build Alternative Components....................................................................................7

Figure 2: Task 6 Build Alternative Components...................................................................................9

4.0 SUMMARY OF EFFECTS ...................................................................................................................10

4.1 Geology and Soils........................................................................................................................10

4.2 Air Quality ...................................................................................................................................10

4.3 Water Resources.........................................................................................................................11

4.4 Wetlands.....................................................................................................................................11

4.5 Ecological Resources and Threatened & Endangered Species ...................................................12

4.6 Energy and Climate Change ........................................................................................................14

4.7 Noise ...........................................................................................................................................15

4.8 Vibration .....................................................................................................................................15

4.9 Hazardous Materials...................................................................................................................15

4.10 Land Use and Recreation ............................................................................................................16

4.11 Cultural and Historic Resources ..................................................................................................16

4.12 Section 4(f) Resources.................................................................................................................17

4.13 Socioeconomics and Environmental Justice ...............................................................................18

4.14 Aesthetics....................................................................................................................................18

4.15 Transportation ............................................................................................................................19

4.16 Public Services, Utilities, and Safety............................................................................................19

5.0 INDIRECT EFFECTS ...........................................................................................................................19

6.0 CUMULATIVE EFFECTS.....................................................................................................................20

7.0 PUBLIC INVOLVEMENT....................................................................................................................20

8.0 ENVIRONMENTAL COMMITMENTS.................................................................................................21
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9.0 CONCLUSION...................................................................................................................................21

List of Appendices:

Appendix A: Section 4(f) de minimis Impact Analysis

Appendix B: Environmental Commitments, Minimizations, and Best Management Practices 

Appendix C: Environmental Assessment Comments and Responses

Appendix D: Resource Agency Consultation 
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1.0 INTRODUCTION

The Washington State Department of Transportation (WSDOT) is implementing a program of 

infrastructure improvement projects along the Pacific Northwest Rail Corridor (PNWRC) also known as 

the PNWRC Improvement Program (Program). The PNWRC Improvement Program is made up of

approximately 17 component projects defined in terms of improvements to passenger rail service along 

the PNWRC and is designed to improve passenger rail service, or “service outcomes,” in Washington 

State. To fund these projects, WSDOT applied and was selected for grant funding through the Federal

Railroad Administration’s(FRA) High-Speed Intercity Passenger Rail (HSIPR) Program. FRA completed a 

Programmatic Environmental Assessment (EA) analyzing the potential impacts of the PNWRC 

Improvement Program that resulted in FRA issuing a Finding of No Significant Impact (FONSI). In that 

Tier I Programmatic EA and FONSI, FRA anticipated completing project-level analysis for each of the 

independent component projects.1

Although the projects to improve service outcomes are distributed throughout the PNWRC, some 

projects are clustered in certain geographic areas and address specific conditions that result in delays 

to passenger rail service. One such area is composed of three independent projects referred to as 

the Kelso Martin’s Bluff Improvement Projects. The Kelso Martin’s Bluff Improvement Projects Tasks 

5: New Siding and Task 6: Kelso to Longview Junction are proposed to improve passenger rail 

operations around the Port of Kalama and the Port of Longview in Washington State.

2

 Tasks 5 and 6

would help facilitate two additional Amtrak Cascades service round trips between Portland, Oregon 

and Seattle Washington, with improved reliability and reduced travel time and would also support 

Amtrak’s longer-distance Pacific Northwest passenger rail service, the Coast Starlight. The majority of 

Tasks 5 and 6 construction activities will occur on rail infrastructure owned by the BNSF Railway. 

FRA and WSDOT prepared a Project-level Environmental Assessment (EA) for Tasks 5 and 6 to analyze

and document whether these two Tasks would have significant effects on the environment. The EA was 

circulated for public review and comment between August 28 and September 27, 2014.This Finding of No

Significant Impact (FONSI) is made based on the information in the EA and has been prepared by FRA in 

compliance with the National Environmental Policy Act of 1969 (42 U.S.C § 4321) (NEPA), FRA’s 

Proceduresfor Considering Environmental Impacts (64 Fed. Reg. 28545, May 6, 1999), and other

related laws.

The final version of the EA is available to the public on FRA’s website at

http://www.fra.dot.gov/Page/P0212 and WSDOT’s Project website at: 

http://www.wsdot.wa.gov/projects/rail/kelsolongviewjct/ and 

http://www.wsdot.wa.gov/projects/rail/kelsonewsiding/.WSDOT intends to use FRA’s decision 

document and other supporting documentation to satisfy the Washington State Environmental Policy 

Act (SEPA) (RCW 43.21C). 

 1 While the individual projects making up the PNWRC Improvement Program will collectively improve passenger rail service in 

Washington, each project was identified in the Programmatic EA and has independent utility and is therefore capable of being 

analyzed in separate NEPA documents. 2 The third Kelso-Martin’s Bluff project (Task 4, Toteff Road Siding), was evaluated separately with a Categorical Exclusion.
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2.0 PURPOSE ANDNEED

The purpose for both Task 5 and Task 6 is to improve reliability, enhance efficiency, and enhance 

frequency of HSIPR service along the PNWRC through the Kalama and Kelso, Washington, areas by 

relieving passenger rail congestion related to freight rail traffic entering and exiting the Ports of Kalama 

and Longview. 

Task 5 and Task 6 are needed to relieve passenger-freight rail congestion and interference in and around 

the Ports of Kalama and Longview, especially along the two existing main line tracks, which are used by 

both intercity passenger and freight rail operations. The current track configuration results in 

congestion and ultimately in service delays that adversely affect passenger train scheduling and 

reliability. Currently, freight rail traffic arriving and departing from the Ports of Kalama and Longview 

frequently blocks one main line track for extended periods of time limiting operations to a single track. 

This inhibits the ability of passenger and other freight traffic to meet and pass on the main line leading

to delays and does not allow for the addition of new intercity passenger rail frequencies.

3.0 DESCRIPTIONOF ALTERNATIVES

Planning to improve passenger rail service for the Portland–Seattle–Vancouver, British Columbia, 

segment of the PNWRC began in 1993 under an FRA high-speed rail initiative. The corridor service 

planning effort, which came to be known as the PNWRC Improvement Program, led to the identification 

of capital improvements needed to meet and expand passenger rail program service outcomes over a 

20-year time frame. Improvements in the Kelso Martin’s Bluff area were identified in the planning for 

the PNWRC Improvement Program. 

In 2003, FRA and WSDOT initiated an Environmental Impact Statement (EIS) to evaluate rail 

improvements in the Kelso Martin’s Bluff area. The EIS considered three alternative track alignments as 

build alternatives, with the addition of approximately 19 miles of track and improvement of track 

transitions. The preliminary preferred alternative was of much larger scope than the proposed Task 5 

and 6 projects, and was expected to result in significantly greater environmental impacts. Due to the 

potential impacts and the projected costs, the project was not advanced. 

In 2006, to consider means to achieve the corridor service objectives with fewer environmental impacts

and more cost-effective improvements, WSDOT reexamined projects identified in the PNWRC 

Improvement Program. This effort resulted in the Washington State Long-Range Plan for Amtrak 

Cascades and included the Kelso Martin’s Bluff projects, as they were identified, as important 

components to improve service outcomes. In 2008, WSDOT developed the Amtrak Cascades Mid-Range 

Plan, which provided for the phased implementation of the PNWRC Improvement Program, and 

identified individual projects in the Kelso Martin’s Bluff area, including the Task 5 and 6 projects 

examined in the recent EA.

In early 2009, as part of the required NEPA compliance for funding eligibility under FRA’s HSIPR grant 

program, WSDOT and FRA completed the Pacific Northwest Rail Corridor, Washington State Segment –

Columbia River to the Canadian Border Program Environmental Assessment. In this 2009 Programmatic 

EA, the Kelso-Martin’s Bluff phased projects identified in the 2008 Amtrak Cascades Mid-Range Plan

were refined with additional planning and operational modeling to reduce both environmental impacts

and cost. The Programmatic EA analyzed the Corridor Service Expansion Alternative, which included 

Tasks 5 and 6 as part of the Kelso Martin’s Bluff suite of projects. The purpose of the Corridor Service 

Expansion Alternative was to improve passenger rail service. In 2010, FRA issued a FONSI, directing 
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project-level environmental reviews. Consistent with that Programmatic EA, two alternatives are 

considered in the subject EA for Tasks 5 and 6, the No Build Alternative and the Build Alternative.

3.1 No Build Alternative

The No Build Alternative for both Task 5 and Task 6 includes only minor maintenance and repair 

activities necessary to keep the existing rail line operational for existing freight and intercity passenger 

rail service. Amtrak’s Cascades and Coast Starlight passenger train service would continue to use the 

existing rail line through the Ports of Kalama and Longview. However, the No Build Alternative would not 

include any other improvements to passenger rail, and delays due to congestion in the Task 5 and Task 6 

project area would continue. The service outcomes for improved or additional intercity passenger train 

service would not be achieved because an increase in Amtrak service would further increase existing 

congestion and result in adverse effects on both freight and passenger rail operations. 

3.2 Build Alternative

The EA analyzes build alternatives for Task 5 and Task 6. While they are addressed in the EA together,

the improvements are specific to each project location and each addresses inefficiencies and delays 

related to rail congestion at two discrete locations (i.e. the Port of Kalama (Task 5) and the Port of 

Longview (Task 6)) which could be constructed independently of each other. The Task 5 and Task 6 

projects include improvements to support improved passenger service schedule reliability, improved 

travel times, and increased frequency in Amtrak service between Portland and Seattle from four to six

daily round trips. The Build Alternative for Task 5 and Task 6 would improve the flow of passenger trains 

through Kalama and Kelso by establishing a new main line for passenger train use and new track 

switching that would improve the transition of freight rail traffic off the main line tracks as those trains 

travel to and from the Ports of Kalama and Longview. The Build Alternative for Task 5 and Task 6 would 

allow Amtrak trains to operate at speeds up to 79 miles per hour (mph). 

3.3 MAPS

As shown on Figure 1, the Task 5 project includes:

• construction of approximately 4.1 miles of a third main line track to the east of the existing 

double-track main line, from the vicinity of Toteff Road north to the Kalama River; 

• installation of higher-speed turnouts on new embankment at both ends of the new track to 

facilitate train movements on and off the new third main line track, and modification of signal

control points (CPs) and installation of intermediate signals to aid in dispatch, train control, and 

accommodation of all passenger rail operations; 

• construction of crash walls under a roadway overpass located at Oak Street (MP 106.81) and at 

an existing pedestrian overpass (MP 107.60); 

• grading, excavation, retaining wall and embankment construction, and culvert extension and 

armoring; 

• armoring along approximately 200 feet of the new third main line grade limits near MP 107.50;

• extension of seven stormwater culverts beneath the track bed to accommodate the third main 

line track;

• culvert replacement at unnamed tributary 3 with a fish-passable culvert, installed through Louis 

Rasmussen Day Use Park; and,

• relocation of utilities that are affected by the proposed improvements, as necessary.
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Figure 1: Task 5 Build Alternative Components
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As shown on Figure 2, the Task 6 project includes:

• construction of approximately 3.7 miles of a third main line track, installation of new turnouts, 

crossovers, and removal of other existing turnouts; 

• modification of signal control points;

• construction of a new single-track bridge over the Coweeman River, and installation of a 

maintenance walkway on the existing Coweeman River Bridge; 

• replacement of the existing concrete box structure with a widened rail bridge over South Pacific 

Avenue at MP 99.10, and construction of a new rail bridge over a private road at MP 

101.60;related grading and utility work;

• construction of a retaining wall at MP 102.5;

• grading, excavation, and embankment construction to support the new improvements; and,

• relocation of utilities that are affected by the proposed improvements, as necessary.
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Figure 2: Task 6 Build Alternative Components
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4.0 SUMMARY OF EFFECTS

Environmental effects of the Build Alternative for each task are summarized in this section. Specific effects 

are identified by task, where appropriate.

4.1 Geology and Soils

Short-term effects on soils in the Task 5 and Task 6 project areas would occur from the temporary 

disturbance due to land clearing and excavation into existing slopes and embankments which would 

expose soils in the project areas, increasing susceptibility to wind and water erosion. Though the Task 5 

project is located within an aquifer recharge area, no short-term effects to the aquifer recharge area are

anticipated as there would not be a significant increase in impervious surfaces during construction. The

Task 6 study area contains soils that have moderate to high liquefaction potential. However, these shortterm effects would be minimized by adhering to the best management practices (BMPs) described in 

Appendix B of this document. 

No long-term effects on soils are anticipated. Areas in the Task 5 study area currently susceptible to 

geologic hazards (i.e., geologic critical areas) would continue to be susceptible; however, the Task 5 

project would not increase the long-term susceptibility of the study area to these hazards. Though the 

Task 5 project is located within an aquifer recharge area, there would be only a negligible increase in 

impervious surfaces; therefore, no long-term effects on aquifer recharge are expected. The Task 6 study 

area contains soils that have moderate to high liquefaction potential. However, no long-term effects from 

these soils would occur because WSDOT will design and construct the projects to minimize or eliminate 

potential impacts.

3

 For example, the design would include methods to provide additional soil stabilization, 

which would minimize the potential effects of soil liquefaction should an earthquake occur. 

FRA finds that the Task 5 and Task 6 Build Alternatives would not result in significant adverse effects to 

geology or soils. 

4.2 Air Quality

Neither the Task 5 nor the Task 6 project would result in significant air quality impacts. Construction

would result in a temporary increase in Mobile Source Air Toxics emissionsin the study area, and

temporary odors may be detected by people near asphalt paving operations. However, these impacts 

would be minor andtemporary and would be further reduced through WSDOT’s implementation of

appropriate measuresto control particulate matter emissions during construction (see Appendix B).

The projects conform to Clean Air Act requirements and would not cause exceedances of the National

Ambient Air Quality Standards (NAAQS). The projects are not predicted to increase regional highway

vehicle miles traveled, and thus would not affect regional air pollutantlevels. Increased locomotive

emissionsresulting from additional Amtrak Cascadesservice frequency would be somewhat offset by the

reduction in passenger and freight train idling around the Ports of Kalama and Longview resulting from the

Build Alternative. 

FRA finds that the Task 5 and Task 6 Build Alternatives would not result in exceedances of the NAAQS or 

result in significant air quality effects.

 3 While it is anticipated that WSDOT will contract the construction of the projects to the BNSF Railway, WSDOT is responsible for 

ensuring all minimization and avoidance measures during design and construction are fully implemented.
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4.3 Water Resources

Neither Task 5 nor Task 6 would result in a significant effect on water resources. During construction, 

WSDOT would implement the required environmental commitments and BMPs to minimize or avoid 

erosion, sedimentation, and pollutant spill effects to surface water, surface hydrology or water quality,

and groundwater resources (see Appendix B). The Build Alternatives would not affect surface waters 

through changes in volume or water quality. No changes would be made within the boundaries of 

regulated shorelines or floodplains. The operation of the Build Alternative would not affect surface 

waters, critical aquifer recharge, or well protection areas.

Within the Task 5 study area, the Task 5 project includes the permanent placement of approximately

15,000 cubic yards of material in floodplains. For the new third main line, this includes fill in Wetland B,

which acts as stormwater conveyance for the city of Kalama. The fill placement in Wetland B would affect 

stormwater conveyance capacity and could result in flooding; however, hydraulic modeling indicates that 

base flood elevations would be maintained by implementing the mitigation measure of expanding 

Wetland B. Replacement of the culvert at unnamed tributary 3 with a larger diameter culvert would allow 

for more water to flow at a lower velocity through the culvert and reduce the potential for flooding. 

For the Task 6 project, no short- or long-term effects on floodways and floodplains are anticipated because 

the Task 6 project would not permanently alter or raise the base flood elevations for the floodplains in the 

study area beyond the regulatory base flood elevations established by FEMA. Construction activities 

associated with the Task 6 project are not anticipated to change the flood protection associated with the 

Coweeman River.

FRA finds the construction and operation of the Task 5 and Task 6 Build Alternatives would not result in 

significant impacts to water resources or floodplains. WSDOT would implement appropriate BMPs and 

adhere to the requirements set forth by the U.S. Army Corps of Engineers (USACE) Seattle District, the U.S, 

Fish and Wildlife Service (USFWS), and the National Marine Fisheries Service (NMFS) during the 

consultations completed as part of the EA. As part of the permitting processes to be undertaken by the 

USACE Seattle and Portland districts, and the Washington State Department of Ecology (Ecology) for water 

resources, additional project conditions may be established. FRA anticipates that these conditions would

be included as commitments secured and enforceable through the any required Clean Water Act Section 

404 permitting process, and WSDOT would be responsible for adhering to any such conditions during 

project implementation. 

4.4 Wetlands

The projects have been designed to avoid wetlands impacts to the extent feasible and, with the mitigation 

proposed as part of the NEPA process, neither Task 5 nor Task 6 would result in a significant effect on 

wetland resources4

. Project activities in the wetland sites and Waters of the U.S. are under the jurisdiction 

of the USACE, Seattle District and the US Coast Guard (USCG). Applicable requirements include, but are

not limited to, a Clean Water Act Section 404 permit from the USACE and a Section 401 Water Quality 

Certification from Ecology. For the proposed rail bridge crossing of the Coweeman River, a Section 9 permit 

and a Section 10 permit under the Rivers and Harbors Act are needed from the USCG and USACE 

respectively. Prior to construction, BNSF Railway and WSDOT would coordinate with Ecology, USACE, and 

 4 The 2009 Tier I Programmatic EA FONSI states that all practical measures to minimize wetland impacts will be taken. That FONSI 

further states that compensation for wetland impacts will be provided through purchase of credits in an approved wetland 

mitigation bank. If an approved wetland mitigation bank is not available at the time of permitting, then mitigation will occur 

through the purchase of additional lands and any conditions stipulated by the USACE.
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USCG to secure the necessary permits, and during construction will implement the mitigation as required 

for the Section 404 and 401 Permits, Section 9 and 10 permits, and any others that may be required.

For both the Task 5 and Task 6 Build Alternatives, short-term effects on wetlands during construction 

would result from increased sedimentation and placement of temporary fill, which would temporarily 

decrease water quality and reduce habitat availability. Construction effects on wetland vegetation would 

decrease the ability of wetlands to reduce water velocities during storm events. However, minimization 

measures and environmental commitments (see Appendix B) would be implemented to minimize or 

eliminate effects on wetlands. Once construction is completed, temporary fill would be removed from 

wetlands, and the wetlands would be restored to their pre-existing conditions.

Long-term effects of the Task 5 project would include permanent placement of fill in 3.6 acres of wetlands, 

while the Task 6 project would include permanent placement of fill in approximately 6.8 acres of wetlands. 

This would decrease wetland functions related to flood water conveyance and habitat functions in the 

respective study areas. These long-term permanent effects from construction would be mitigated through 

purchase of mitigation bank credits (as contemplated in the Tier I Programmatic Evaluation) and fee 

acquisition of wetland properties for permanent preservation. The operation of the Build Alternatives

would not affect wetlands. 

FRA finds that no significant impacts to wetlands would occur after implementation of the mitigation 

measures identified in coordination with the USACE and Washington state agencies. FRA anticipates that 

these mitigation measures would also be included as commitments secured and enforceable through the 

Clean Water Act permitting process. 

4.5 Ecological Resources and Threatened & Endangered Species

Neither Task 5 nor Task 6 would result in a significant effect on ecological resources or threatened and 

endangered species. For both Tasks, short-term effects to certain ecological resources would occur as a 

result of vegetation removal during project construction that would temporarily affect water quality and 

may result in the introduction of noxious weeds to the project area. Because of the relatively small scale of 

the permanent vegetation removal, there would be no alteration of the overall vegetative communities in 

either the Task 5 or Task 6 study area. The removal of vegetation would have little effect on wildlife 

because species would likely relocate to other vegetated areas in the vicinity until construction is 

complete. WSDOT would implement minimization measures and BMPs to minimize or eliminate effects 

on these ecological resources. 

The EA assumed that construction windows would limit effects to the threatened streaked horned lark, 

which may exist in both the Task 5 and Task 6 project areas. With this understanding, FRA and WSDOT 

undertook an informal consultation with the USFWS pursuant to Section 7 of the Endangered Species Act 

of 1973. However, as project engineering evolved, WSDOT determined that the construction might occur 

during those periods when the streaked horned lark could be nesting; therefore, FRA initiated formal 

consultation with USFWS.

During formal Section 7 consultation, USFWS found that the major construction activities for both project 

areas (placement of a rock base layer, embankment material, sub-ballast and ballast materials; installation 

of new track using a track laying machine and various other equipment, and modification of a upland berm 

near the south end of the streaked horned lark habitat area) could occur within 100 meters of occupied 

and/or suitable habitat for streaked horned larks. The USFWS’ Biological Opinion found that while the 

species would not be jeopardized, there could be incidental takes in the form of harm or harassment 
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resulting from mortality, disturbance, displacement, and/or depredation. Therefore, the USFWS 

established two reasonable and prudent measures (RPMs) to minimize impacts of incidental take of 

streaked horned larks as well as terms and conditions to implement those RPMs. These terms and 

conditions are incorporated into this FONSI as environmental commitments presented in Appendix B.

With respect to Columbia White Tailed Deer (CWTD), the USFWS found that the Project would result in an

insignificant effect on individual deer with no population consequences. However, the increased number 

of trains (four) and increased average speeds were anticipated to cause indirect effects in the form of

potential train-deer collisions. USFWS projected that the mortality of 11 CWTD over the next 20 years is a 

reasonable expectation. Therefore, USFWS established a RPM for both the Task 5 and Task 6 projects to 

minimize the frequency of deer-train collisions with CWTD. Terms and conditions to support this RPM 

were established, and are incorporated into this FONSI as environmental commitments presented in 

Appendix B.

Temporary and permanent fill in streams would reduce available aquatic habitat, and increases in turbidity

during construction would temporarily affect aquatic species. Pollutant release during construction could 

be transported into streams and affect fish and their prey species. Construction-related in-water work 

would include dewatering and isolation of work areas that would require fish handling and may result in 

elevated stress levels or direct mortality. 

The Task 5 project area hosts two ESA-listed threatened fish species, the Lower Columbia River Steelhead 

Distinct Population Segment (DPS), and the Lower Columbia River Coho salmon. In addition, there is also 

essential fish habitat (EFH) for Pacific salmon. Based on the effects described above, described in the 

biological assessment prepared in conjunction with the EA, the Task 5 project may affect, and is likely to 

adversely affect, Lower Columbia River Coho ESU, Lower Columbia River steelhead DPS, and critical habitat 

associated with the Lower Columbia River Coho salmon. Coho salmon are known to be present in 

unnamed tributary 3 and the streambed would be temporarily affected by the culvert replacement.5

The Task 5 project requires authorization from the National Marine Fisheries Service (NMFS) under the 

Magnuson-Stevens Act (MSA). As part of this consultation, NMFS determined that the Task 5 project area 

includes areas designated as EFH for Coho salmon and Chinook salmon, but the project does not occur 

within a Habitat Area of Particular Concern. NMFS further determined that construction of Task 5 may 

adversely affect Pacific salmon EFH within the study area. 6

 NMFS identified terms and conditions to offset 

the impact of the proposed action on EFH. The terms and conditions are listed in Appendix B as 

environmental commitments. 

NMFS also provided conservation recommendations which include a work window definition; 

commitments to reduce disturbance and turbidity during in-water work; and minimization of damage and 

vegetation removal as practicable. See Appendix B for these recommendations, which would be required 

as part of the Task 5 project.

The Task 6 project area hosts several ESA-listed threatened or endangered fish species, including the 

Lower Columbia River Chinook Salmon, Upper Columbia River spring-run Chinook Salmon, Snake River fallrun Chinook Salmon, Snake River spring/summer-run Chinook Salmon, Upper Willamette River Chinook 

 5 Although there would be disturbance during construction at UT3, with the new culvert in place, habitat for Coho salmon would be 

significantly improved, with the creation of new spawning, nursery and foraging habitat. 6 Critical habitat has been proposed for the LCR coho salmon in the project area but has not been designated by NMFS.
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Salmon, Columbia River Chum salmon, Lower Columbia River Coho Salmon, Snake River Sockeye salmon, 

Snake River basin Steelhead, Upper Columba River Steelhead, Middle Columba River Steelhead, Lower 

Columba River Steelhead, Upper Willamette River Steelhead, and Southern Pacific Eulachon. In the Task 6 

area, there is also EFH supporting the Pacific coast Salmon. NMFS has determined through the ESA 

consultation process that Task 6 could affect all of the species named above. Therefore, NMFS has 

identified reasonable and prudent measures to avoid the effects to the species and destruction and

adverse modification of critical habitat. The reasonable and prudent measures include methods to 

minimize incidental take resulting from elevated suspended sediments, impact pile driving, fish handling 

and from the loss of off-channel habitat. The terms and conditions established by NMFS to bring these 

measures into effect are listed in Appendix B as environmental commitments.

As a result of the MSA consultation for Task 6, NMFS determined that construction of the Task 6 project 

may adversely affect Pacific salmon EFH within the Task 6 study area. However, NMFS also determined 

that the conservation measures required by the Biological Opinion described above and its terms and 

conditions to minimize elevated suspended sediments during construction are sufficient to offset the 

impact of the proposed action on EFH. In-water work will occur to construct the new rail span at the 

Coweeman River; effects to fish habitat would be minimized or eliminated through the implementation of 

BMPs and minimization measures (see Appendix B).

Mitigation to offset impacts to fish habitat would include the replacement of two undersized culverts at 

the private access road at MP 100.29, and the Owl Creek Sand and Gravel Company access road at MP 

101.6. This mitigation would enhance connectivity between fish bearing streams and associated wetlands 

and improve overall water quality and available habitat. Mitigation is further described in Appendix B.

FRA finds that no significant impacts to ecological resources or rare, threatened, and endangered species 

would occur after implementation of the terms and conditions for the protection of the Columbia White 

Tail Deer, streaked horned lark, and the several ESA-listed threatened or endangered fish species

developed in consultation with the USFWS, NMFS, and the Washington Department of Fish and Wildlife. A 

copy of the Task 5 Biological Opinion and the Task 6 Biological Opinion are included in Appendix D.

4.6 Energy and Climate Change

There would be no substantial change in short- or long-term fuel consumption, energy use, or greenhouse 

gas (GHG) emissions in Washington State from the Task 5 Project or from the Task 6 Project. The potential 

increase in energy use and GHG emissions would be minimized by adhering to minimization measures and 

BMPs (see Appendix B). Neither project would contribute substantially to potential climate change.

Construction of the Task 5 project would require 231,224,343 million British thermal units (MBtu) of 

energy and would generate 17,146 metric tons (MT) carbon dioxide equivalent (CO2e) of GHG emissions. 

The CO2e emissions would represent 0.0017 percent of the total GHGs emitted in Washington State. This 

would not represent a substantial contribution to GHG emissions in Washington State or the Task 5 project

area. Construction of the Task 6 project would require 479,872,000 MBtu of energy and would generate 

35,500 MT CO2e of GHG emissions. The CO2e emissions would represent approximately 0.0037 percent of 

the total GHGs emitted in Washington State. This would not represent a substantial contribution to GHG 

emissions in Washington State or the Task 6 project area and thus would not be expected to contribute 

substantially to potential climate change.

The Task 5 and Task 6 projects were also assessed for potential effects upon them from climate change. 

Studies performed by WSDOT indicate that State Route 411 near the project area has the potential to be 
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Finding of No Significant Impact

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highly affected by river flooding and sea level rise. FRA and WSDOT considered this information during 

preliminary design. The Task 5 and Task 6 projects are designed to last more than 50 years. As part of their 

design, the Task 5 and Task 6 projects have incorporated features that would provide greater resilience 

and function with the potential effects brought on by climate change. 

FRA finds that no significant impacts to energy or climate change would occur as a result of construction or 

operation of the Task 5 and Task 6 project. In addition, the project has been analyzed for impacts from 

climate change and the Task 5 and Task 6 projects have incorporated standard design features that would 

provide greater resilience and function with the potential effects brought on by climate change.

4.7 Noise

Neither Task 5 nor Task 6 would result in a significant noise impacts. Construction of Task 5 and Task 6

would result in localized increasesin noise levels. These increases would be typical of those emitted from

construction equipment and materials delivery vehicles. However, not all equipment operates at full power 

constantly through the construction period and average daytime noise levels would be affected only 

temporarily. Construction noise effects on sensitive receptors are not anticipated to be significant.

For Task 5, short-term, minor noise from construction sources would occur for residents and visitors to Louis 

Rasmussen Day Use Park, a Section 4(f) resource. These effects would be minimized by adhering to 

minimization measures and BMPs identified in Appendix B. 

During Task 6 construction, there would be noise from pile driving activities associated with the Coweeman 

River Bridge. Short-term, minor noise effects would occur for the Task 6 project from temporary noise 

generated during construction at the bridge. However, the temporary noise would not impact the public, 

since it does not have access to the bridge. The Washington State Department of Archaeology and Historic 

Preservation (DAHP) concurred with FRA and WSDOT’s determination that the noise generated by the 

project would not result in an adverse effect to the bridge, which is a National Register-eligible property. 

A long-term, marginal increase in noise would occur from operation of trains under Tasks 5 and 6. However, 

no moderate or severe impacts are anticipated, and the minimization measures and BMPs in Appendix B 

would be incorporated into the project. No significant noise impacts are predicted in the Task 5 study area 

and the slight increase in noise at the Rasmussen Day Use Park will not substantially impair the public’s use 

and enjoyment of the Park. No moderate or severe impacts are projected, and significant effects would not 

occur.

4.8 Vibration

The vibration resulting from the project construction and operation would be below the FTA vibration 

impact thresholds and therefore neither Task 5 nor Task 6 would result in a significant vibration impacts. 

4.9 Hazardous Materials

Neither Task 5 nor Task 6 would result in a significant hazardous materials impact. Short-term effects 

would be expected during construction of the Task 5 and Task 6 projects if contaminated soil, sediment, or 

groundwater were encountered; however, these effects would be minimized by adhering to the measures 

described in Appendix B. The project is intended to improve passenger train operations and there would 

be no foreseeable increase in the freight rail transport of hazardous material as a result of the Build 

Alternative. Therefore, no long-term effects from either project are anticipated because the project would 

not increase the potential for exposure to hazardous materials from the transport or accidental release of 

hazardous materials. 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 16

FRA finds that the Task 5 and Task 6 Build Alternatives would not result in hazardous materials impacts

since known or potentially contaminated sites have been identified and any unanticipated sites would be 

treated in accordance with state and federal requirements. Appropriate design measures would be 

implemented to avoid known contaminated sites.

The construction and operations do not include major increases in the use or possible accidental release of 

any significant amounts of hazardous materials. Thus minimal impact is expected from the use of small 

amounts of hazardous materials during construction and operations in both Task 5 and Task 6. No longterm effects from the Task 5 project are anticipated because the project would not increase the potential 

for exposure to hazardous materials from the transport or accidental release of hazardous materials. 

Amtrak Cascades trains operating in the Task 5 study area would not be carrying hazardous materials in 

bulk. The current commodity mix hauled by BNSF Railway freight trains, which may include hazardous 

materials, would continue to be transported through the Task 5 and Task 6 study areas and the risk of a 

hazardous materials incident would be comparable to current conditions. Proposed operational activities 

would not affect ongoing remediation activities at any of the hazardous materials sites of concern. 

Accidental hazardous materials spills or releases from operational activities, equipment, or materials may 

occur but would be comparable to current conditions. 

4.10 Land Use and Recreation

Neither Task 5 nor Task 6 would result in significant impacts to land use or recreation. Both the Task 5 and 

Task 6 projects would be consistent with all applicable land use plans and policies and would not affect 

future development opportunities of property adjacent to the railroad right-of-way. Neither project would 

result in any regional or local changes to adjacent land use, with the exception of lands purchased for the 

purpose of offset mitigation for Task 6 wetlands impacts and wildlife effects; those lands would be 

permanently preserved and managed for wetlands, wildlife and open space purposes. Refer to Section 4.4 

of this FONSI for effects on wetlands in the study areas.

No short-term effects on land use would be anticipated from construction activities associated with Tasks

5 or 6. Construction activities associated with the culvert replacement at unnamed tributary 3 would have 

a short-term effect on recreation and users of Louis Rasmussen Day Use Park, a Section 4(f) resource

(discussed further in Section 4.12). Construction activities would require temporary closure of the beach,

parking area, and Hendrickson Drive within the construction site of unnamed tributary 3 fish-passable 

culverts; fishing access in the construction area would be unavailable during the construction period. The 

Port of Kalama’s unpublished master plan describes future improvements to the park, and the proposed 

culvert changes at unnamed tributary 3 would not conflict with proposed circulation improvements in its 

vicinity. 

Both Task 5 and Task 6 are consistent with adopted land use policies. However, the Task 6 project would 

be located partly adjacent to the runway at the Southwest Washington Regional Airport in Kelso. 

Notification of FAA under 49 CFR 77 to document the proposed activities has taken place. Although the 

project is close to the runway, the proposed project and construction would have a low profile, similar to 

the existing rail activities and are not anticipated to effect airport operations.

The rail corridor would continue to be compatible with surrounding land uses and FRA finds the Project 

would not result in significant effects to local land use.

4.11 Cultural and Historic Resources
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 17

Neither Task 5 nor Task 6 would result in significant impacts to cultural or historic resources. Federallyrecognized tribes and the Washington State Department of Archaeology and Historic Preservation (DAHP)

were consulted, as required by Section 106 of the National Historic Preservation Act. No historic 

structures or Traditional Cultural Properties (TCPs) were identified in the Task 5 or in the Task 6 project 

Areas of Potential Effect (APE). No archaeological resources were identified in the Task 6 project APE. 

Replacement of the unnamed tributary 3 culvert would require construction in areas that were not 

included in the originally evaluated APE, and the construction work could encounter native soils that may 

contain archaeological resources. In consultation with DAHP, archaeological testing was conducted by 

WSDOT to assist in determining if archaeological resources are present. No cultural material was 

encountered during testing; however, results of the subsurface investigation indicate a potential for intact 

archaeological resources in the project area. Therefore, WSDOT will provide archaeological monitoring 

during construction activities exceeding depths of 15 feet below surface (approximate depth of natural soil 

surface) and an Inadvertent Discovery Plan (IDP) will be developed, in consultation with DAHP, to establish 

procedures for addressing the unanticipated discovery of archaeological resources during construction 

activities.

The Task 6 project area includes the National Register-eligible Coweeman River Bridge, which would itself 

be modified through the addition of lighting and a pedestrian walkway for maintenance workers. In 

addition, a second rail bridge over the Coweeman River would be constructed proximate and generally 

parallel to the existing Coweeman River Bridge. The bridge modifications and the construction of the 

second rail bridge proximate to the existing bridge were reviewed in consultation with DAHP. FRA 

determined, with DAHP concurrence, that no adverse effects would occur with the modifications to the 

existing bridge, and the changes to the viewshed of the resource were similarly not significant.

DAHP concurred with FRA’s finding of no adverse effect on cultural resources and historic properties. 

Copies of DAHP concurrence letters are included in Appendix D. FRA finds the Project would not adversely 

affect historic properties.

4.12 Section 4(f) Resources

There are Section 4(f) resources in both the Task 5 and Task 6 study areas. The Louis Rasmussen Day Use 

Park in the Task 5 study area would be affected by that project. The Task 6 project area includes the 

Coweeman River Bridge which has been found eligible for listing in the National Register of Historic Places.

At Louis Rasmussen Day Use Park, construction activities associated with the culvert replacement at 

unnamed tributary 3 would have short-term effects. Access to this park would be maintained during 

construction, although there could be temporary unavailability of parking in the immediate area of the 

construction. Construction noise would be generated near the park, although it would dissipate as the 

distance from construction activities increases, and would be temporary. These short-term effects would 

not substantially impair the activities, features, or attributes of the Section 4(f) resource. 

FRA finds that the impacts to the Louis Rasmussen Day Use Park would be de minimis. The Port of Kalama 

(Port), the official with jurisdiction over the resource, concurred in writing with this finding on December 

9, 2014. WSDOT will implement all minimization measures included in the Port’s concurrence letter as a 

condition of implementing the Task 5 Project. These minimization measures are further discussed in 

Appendix A.
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 18

Testing was conducted by WSDOT to establish the potential for archaeological resources in the vicinity of 

the unnamed tributary 3 construction. While no cultural materials were encountered during testing, 

WSDOT will provide archaeological monitoring during construction activities exceeding depths of 15 feet 

below surface and an IDP will be developed, in consultation with DAHP, to establish procedures for 

addressing the unanticipated discovery of archaeological resources during construction activities. DAHP 

concurred in writing with FRA’s finding that no historic properties would be affected by the construction at 

the Louis Rasmussen Day Use Park, but that archaeological monitoring and development of an IDP are 

appropriate to address unanticipated discoveries. If archaeological resources are discovered, FRA and 

WSDOT, in consultation with DAHP and affected Tribes, will determine National Register eligibility and will 

perform an additional Section 4(f) evaluation if necessary.

The Task 6 project includes the addition of a new walkway, handrails, and lighting to the existing National 

Register-eligible Coweeman River Bridge, which could represent a permanent incorporation of a property 

protected by Section 4(f). In addition, a separate single-track rail bridge would be constructed adjacent to 

the existing Coweeman River Bridge. FRA and WSDOT determined that these new features and the second 

span would not result in an adverse effect to the historic property and sought DAHP’s review of and 

concurrence with that finding. DAHP reviewed the proposed additions to the bridge, and provided

concurrence with FRA’s finding of no adverse effect (April 17, 2014 and August 20, 2013). Based on this 

finding and DAHP’s concurrence, FRA finds that the Task 6 project would have a de minimis impact on the 

Coweeman River Bridge.

The Section 4(f) de minimis Impact Analysis is included in Appendix A. A copy of the Port’s concurrence 

letter is included in Appendix D.

4.13 Socioeconomics and Environmental Justice

Neither Task 5 nor Task 6 would result in significant socioeconomic impacts or disproportionate adverse 

effects to environmental justice communities. Task 5 and Task 6 projects would have the same temporary 

and minor effects on socioeconomic resources. Any short-term effects on employment, income, and local 

expenditures; neighborhoods and businesses adjacent to the rail line; public services; and community 

connectivity and cohesion would be temporary and minor. Such effects could include temporary 

construction noise adjacent to residences, businesses, and recreational areas within the vicinity of the 

projects. This may also affect environmental justice populations; however, no disproportionately high or 

adverse effect on environmental justice populations would result. 

The two passenger rail improvement projects are not anticipated to result in long-term effects on local 

businesses, economic conditions, or public services, and would not cause a direct change in the 

demographics, land use patterns, neighborhoods, or other related community characteristics. Both the 

Task 5 and Task 6 project improvements are within existing railroad right-of-way; therefore, most 

community cohesion factors such as transportation would experience only minor effects that are not 

anticipated to contribute to changes in such cohesion. 

The Task 5 and Task 6 projects have been evaluated pursuant to the requirements of Executive Order 

12898 – Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations, and USDOT Order 5610.2(a). FRA finds that neither the Task 5 nor the Task 6 Build Alternative 

would result in effects to socioeconomic conditions or disproportionate effects to environmental justice 

communities. There would be no change to existing barriers to access or use by elderly persons and 

persons with handicaps. 

4.14 Aesthetics 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 19

Neither Task 5 nor Task 6 would result in significant aesthetic impacts. Short-term effects on visual 

resources, including the Louis Rasmussen Day Use Park, in both the Task 5 and Task 6 study areas would be 

minor and temporary. The overall long-term effects on the visual environment from the introduction of 

these improvements would also be minor. FRA finds that there would be no significant long-term impacts 

to the visual setting of the Project area due to the Project’s location adjacent to the existing mainline track 

and the general land use setting.

4.15 Transportation

Neither Task 5 nor Task 6 would result in significant transportation impacts. Short-term effects on 

transportation would be anticipated during construction of both the Task 5 and Task 6 projects, due to the 

movements of construction vehicles bringing materials through the study area. Construction materials 

would likely be brought to the Task 5 and Task 6 areas by truck, with individual movements occurring daily 

over a 12-hour period. Any resulting traffic delays or queues at intersections and railroad crossings would 

be negligible. 

For Task 5, a temporary reduction in passenger or freight speed would occur during construction of the 

culvert replacement at unnamed tributary 3 in the area between the BNSF right of way and an outfall in 

the Columbia River, via the Louis Rasmussen Day Use Park. The reduction in speed would not result in 

effects on freight or passenger train schedules. Temporary closure of Hendrickson Drive and parking areas 

in the Park would occur for approximately 2 weeks; however, access would be maintained along 

Hendrickson Drive for emergency vehicles. Alternative routes to the Port of Kalama and the Louis 

Rasmussen Day Use Park are available both north and south of the construction site. A traffic control plan, 

notification, and signage which will be developed in consultation with the officials with jurisdiction over 

the Park, would be implemented during construction to minimize effects to adjacent property owners, 

businesses, and park users. These minimization measures are further discussed in Appendix A.

The long-term effects of Tasks 5 and 6 would be beneficial, as the addition of the third main line track and 

installation of higher speed turnouts for each project would improve the operations and flow of passenger 

trains. The additional passenger service through each study area would increase the number of shortterm roadway blockages by the additional four passenger trains crossing throughout the day as compared 

to the No Build Alternative. However, FRA finds that the effects of the Task 5 and Task 6 Build alternatives 

on transportation would be minimal, while passenger rail service would be improved.

4.16 Public Services, Utilities, and Safety

Neither the Task 5 nor the Task 6 project would result in short- or long-term effects on utilities or public 

services because no change in use or demand is anticipated. Utility conflicts within the right-of-way would 

require relocation, deepening, or hardening of utility lines, where appropriate. This could result in 

temporary disruptions in service; however, effects would be minimized by adhering to minimization 

measures and BMPs (see Appendix B). No short- or long-term effects on public or worker safety are

anticipated.

FRA finds that the Task 5 and Task 6 Build Alternatives would not result in significant impacts to public 

health, utilities, or safety.

5.0 INDIRECT EFFECTS

Neither the Task 5 project nor the Task 6 project is likely to directly or indirectly affect growth or land use 

patterns. Growth and development in each study area would occur as forecasted and planned by each 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 20

jurisdiction regardless of project implementation. FRA does not anticipate any significant indirect effects 

to any of the resource areas analyzed in the EA.

6.0 CUMULATIVE EFFECTS

As described in the effects analysis in the EA, the Build Alternative for both Tasks 5 and 6 would have no 

direct or indirect effects on geology and soils, hazardous materials, land use and recreation, 

socioeconomics, or public services. Therefore, FRA and WSDOT determined that the Task 5 and Task 6 

projects would not contribute to a cumulative effect on these resources. 

FRA and WSDOT considered the potential for cumulative effects resulting from the project for resources 

where minor effects may occur. When considered with past, present, and reasonably foreseeable 

future actions, the Task 5 and Task 6 Build Alternatives would not be expected to contribute to a 

significant adverse cumulative effect on any resources. The Build Alternatives, with the implementation 

of mitigation or minimization measures specified in Appendix B, would not contribute to a cumulative 

effect on water resources, ecological resources or threatened or endangered species, aesthetics, 

cultural resources, Section 4(f) resources, or utilities. As with any new construction, there would be 

additional energy expended as a result of the project that would contribute to the cumulative impact on 

energy and greenhouse gas emissions; however, the projects would not contribute substantially to the 

advancement of potential climate change. 

The project would provide some beneficial cumulative impacts on transportation resources and air 

quality. For example, the proposed improved operability of freight and passenger rail service by the 

construction of Tasks 5 and 6 may provide a slight overall benefit to air quality. Air quality benefits are 

also expected as travelers use the faster and more reliable Amtrak service instead of travelling by 

automobile. Improved separation of existing freight train movements from passenger rail train service 

will create a net positive cumulative effect of improving the reliability, speed, and dependability of 

passenger rail service in this segment of the Pacific Northwest rail corridor, which is a purpose of the 

proposed action.

With regulatory oversight provided through the USACE permitting activities, cumulative wetland losses 

due to present and future actions would be offset through mitigation requirements. Therefore, the

Build Alternatives would not contribute to an adverse cumulative effect on wetlands.

FRA finds that the project would not result in any significant adverse cumulative impacts to any of the 

resources analyzed in the EA.

7.0 PUBLIC INVOLVEMENT

Opportunities for public involvement on the project began with the scoping process and other outreach 

efforts that took place in spring 2013. Materials provided at public meetings and briefings included

electronic PowerPoint presentations, project maps, photos, fact sheets, and illustrated project timelines.

FRA and WSDOT’s efforts for the EA included outreach to stakeholders along the project corridor.

WSDOT maintains a project website for the Task 5 project at 

http://www.wsdot.wa.gov/projects/rail/kelsonewsiding/ and the Task 6 project at 

http://www.wsdot.wa.gov/projects/rail/kelsolongviewjct/. 

FRA and WSDOT made the EA available for public review on August 28, 2014 for a period of 30 calendar days.

A total of 115 comments on the EA were received from individuals or agencies, including commentsfrom

three federal agencies, two state agencies, one regional agency, and two local agencies. The comments and 

responsesto them are included in Appendix C.
8.0 ENVIRONMENTALCOMMITMENTS 

As part of its environmental review, FRA identified certain environmental commitments, minimization 

measures, and BMPs as the practicable means to avoid or minimize effects from the implementation of 

Task 5 and Task 6. These measures are listed in Appendix B. Because Task 5 and Task 6 are funded 

through a Cooperative Agreement between FRA and WSDOT, WSDOT is responsible for ensuring that 

all environmental commitments are fully implemented. As part of its oversight role, FRA will conduct 

monitoring during WSDOT's implementation of Task 5 and Task 6 to ensure these requirements are 

met. 

9.0 CONCLUSION 

As described in the EA and further in this FONSI, the Task 5 and Task 6 projects would each improve 

reliability, enhance efficiency, and enhance frequency of HSIPR service along the PNWRC through Kalama 

and Kelso, Washington. The current track configuration results in congestion and ultimately in service 

delays that adversely affect passenger train scheduling and reliability. The Task 5 and Task 6 projects 

would address these operational constraints and relieve passenger-freight rail congestion, especially along 

the two existing main line tracks at the Ports of Kalama and Longview, which are used by both intercity 

passenger and freight rail operations. 

The FRA finds that the EA for the Kelso-Martin's Bluff Task 5 and Task 6 Improvement Projects satisfies the 

requirements of FRA's NEPA "Procedures for Considering Environmental Impacts" (64 FR 28545, May 26, 

1999) and NEPA (42 USC §4321) and that the projects would have no foreseeable significant impact on the 

quality ofthe human or natural environment after implementation of the mitigation commitments 

identified in Appendix B of this FONSI. As the project sponsor, WSDOT is responsible for ensuring all 

environmental commitments identified in Appendix Bare fully implemented. The EA provides sufficient 

evidence and analysis for FRA to determine that an environmental impact statement is not required for 

the project as presented. 

Sarah Feinberg, Acting Administrator 

Federal Railroad Administration 

FRA Contact: 

Laura Shick 

Environmental Protection Specialist 

Federal Railroad Administration 

1200 New Jersey Ave, SE 

Washington, DC 20590 

(202) 366-0340 

List of Preparers: 

Chris Regan, WSDOT 

Leandra Cleveland, HDR Engineering, Inc. 

Ronalee Spellecacy, HDR Engineering, Inc. 

Adam Teepe, HDR Engineering, Inc. 

Kelso Martin's Bluff Improvement Projects 

Task 5 and Task 6 

Finding of No Significant Impact 

Date 

March 2015 

Page 21 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

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Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

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Appendix A: Section 4(f) de minimis Impact Analysis

Kelso-Martin’s Bluff Improvement Projects

Task 5: New Siding

Task 6: Kelso to Longview Junction

Cowlitz County, Washington

Under Section 4(f) of the Department of Transportation Act of 1966 (49 USC §303), the Federal Railroad 

Administration (FRA) may not approve the use of land from a significant publicly-owned public park, 

recreation area or wildlife and waterfowl refuge, or any significant historic site unless a determination is 

made that:7

(i) There is no feasible and prudent alternative to the use of the land from the property; and

(ii) The action includes all possible planning to minimize harm to the property resulting from 

such use, or

(iii) The Section 4(f) use is de minimis.

FRA may determine an impact to park, recreation area, or wildlife and waterfowl refuge is de minimis if:

(i) The transportation use of the Section 4(f) resource, together with any impact avoidance, 

minimization, and mitigation or enhancement measures incorporated into the project, 

does not adversely affect the activities, features, and attributes that qualify the resource 

for protection under Section 4(f);

(ii) The officials with jurisdiction over the property are informed of FRA’s intent to make the 

de minimis impact finding based on their written concurrence that the project will not 

adversely affect the activities, features, and attributes that quality the property for 

protection under Section 4(f); and

(iii) The public has been afforded an opportunity to review and comment on the effects of the 

project on the protected activities, features, and attributes of the Section 4(f) resource. 

FRA may determine an impact to an historic site is de minimis if:

• FRA makes either a “no historic properties affected” or “no adverse effect” determination in 

accordance with Section 106 of the National Historic Preservation Act. 

• The State Historic Preservation Officer (SHPO),8 Tribal Historic Preservation Officer (THPO), as 

applicable and the Advisory Council on Historic Preservation (ACHP), if participating, 9 are notified 

of the intent to make a de minimis impact finding based on their written concurrence in the 

Section 106 determination, and

• The views of any consulting parties participating in the Section 106 process have been considered.

 7 A “use” under Section 4(f) can result from permanent incorporation, temporary occupancy, or proximity impacts that 

substantially impair the activities, features, or attributes that qualify the property for protection (i.e. constructive use). 8 In Washington State, the SHPO office is referred to as the Department of Archaeology and Historic Preservation (DAHP). 9 ACHP did not participate in the review of the Kelso Martin’s Bluff Tasks 5 and 6.
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 24

Once it is determined that a transportation use of Section 4(f) property results in a de minimis impact, 

analysis of avoidance alternatives is not required, and the Section 4(f) process is complete. 

Task 5 - Louis Rasmussen Day Use Park

The Louis Rasmussen Day Use Park (Park) is owned and operated as a recreational facility by the Port of 

Kalama, in Kalama, Washington. The Park provides several different public recreational opportunities, 

including a playground; basketball, volleyball, and tennis courts; horseshoe pits; and picnic areas. The 

beach is immediately accessible, and is used by anglers and beach walkers. All of these resources are 

adjacent and west of the project area, operated by the Port of Kalama, and are open to the public. There 

is Park parking provided between Hendrickson Drive and the BNSF right-of-way, to the east. 

Proposed Project

As an element of Task 5, an existing culvert at unnamed tributary 3 (MP 108.19) that connects waters from 

the east side of the BNSF right of way to the Columbia River would be replaced with two, 60-inch culverts 

that would pass beneath the track bed within the railroad right-of-way. West of the BNSF right-of-way, a 

three-sided bottomless box culvert would be installed beneath Hendrickson Drive and the parking lot 

within Louis Rasmussen Day Use Park. There would be an outfall at the beach, where the box culvert 

would transition to a natural stream channel flowing across the beach use area of the Park. At the culvert 

outfall, a gate would be installed to prevent access into the culvert. The culvert replacement is intended 

to significantly improve fish passability.

Potential Impacts to Louis Rasmussen Day Use Park

The construction of the replacement culverts at unnamed tributary 3 would have temporary effects during 

the construction period. Parking and access in the immediate area of the culvert installation would be 

temporarily closed; however, there is adequate parking nearby in the Park and alternate means of access 

will be provided as part of project construction. There would be a temporary effect on the aesthetics of 

the park, during construction as well as temporary effects from construction noise. Fishing, walking, and 

access to the beach in close proximity to the culvert replacement would also be restricted during the 

construction period. However, these users and activities can be accommodated elsewhere within the Park 

until the culvert construction work is complete and full access is restored. 

The Queen of the West sternwheeler uses the beach in a more southerly portion of the Park for 

passengers to disembark for a bus tour and day trip to Mount St. Helens. Construction activities would be 

approximately 800 feet north of where passengers disembark. Therefore, construction of the unnamed 

tributary 3 culvert replacement would not be anticipated to affect boat landings. Bus loading and 

unloading would also be unaffected by construction as buses utilize a parking area south of the project 

area, which would not be affected during construction. 

Replacement of the unnamed tributary 3 culvert would include a jack and bore pit and trenching to 

install the proposed culverts beneath the rail line, Hendrickson Drive, and parking lot; these activities 

would occur to a depth of 25 feet below ground surface and would therefore likely encounter native 

soils. The construction of the box culvert outfall and natural stream channel along the beach area would 

require shallow excavation that would also encounter native soils. Pre-construction geoarchaeological 

testing conducted by WSDOT in December 2014 did not encounter any archaeological resources. 

However, WSDOT will provide archaeological monitoring during construction activities exceeding depths 

of 15 feet below surface and an Inadvertent Discovery Plan will be developed, in consultation with DAHP, 

to establish procedures for addressing the unanticipated discovery of archaeological resources during 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 25

construction activities for the culvert replacement. 

In addition, to minimize disruption and to protect park visitors, the Port of Kalama has requested specific 

conditions which will be implemented by BNSF and WSDOT during project design and construction:

• Construction Access – A route on Hendrickson Drive capable of supporting emergency services 

will be maintained at all times during construction. This condition will imposed for all 

construction related activities, and included in all appropriate contracting documents.

• Construction Timing – WSDOT and BNSF Railway will coordinate construction timing with the 

Port to avoid impacts to recreation use. A tentative schedule has been discussed with the Port 

and will be refined prior to construction.

• Maintenance – A future maintenance agreement between BNSF Railway and the Port will be 

secured prior to constructing the UT3 culvert.

• Design – Prior to proceeding with final design, WSDOT and BNSF Railway will provide the design 

and review with the Port to ensure park resources and visitor safety are addressed with the 

culvert design. In general, the culvert will be constructed, and following construction the area 

will be restored, in a manner that conforms to the Port’s Louis Rasmussen Day Use Park Master 

Plan.

• Construction – The culvert outfall and natural stream conveyance will be constructed to ensure 

the safety of park visitors.

• Construction – WSDOT will oversee the construction and use WSDOT’s construction BMPs to 

control dust, noise, etc.

Task 6 – Coweeman River Bridge

The Task 6 project would include the construction of a new single-track rail bridge adjacent to the National 

Register-Eligible Coweeman River Bridge, and the addition of a new walkway, handrails, and lighting to the 

existing. FRA determined that these projects could represent a permanent incorporation of a property 

protected by Section 4(f), but further determined that these new features would not result in an adverse 

effect to the historic property and referred that finding to the Washington Department of Archaeology and 

Historic Preservation (DAHP) for their review and concurrence. DAHP reviewed the proposed new bridge 

and the proposed additions to the bridge, and provided FRA with letters concurring with FRA’s findings of 

no adverse effect (letters dated, August 20, 2013 and April 17, 2014, respectively). 

Opportunity for Public Review

FRA’s analysis of the potential de minimis impacts to the Coweeman River Bridge and Louis Rasmussen Day 

Use Park was included in the EA. The EA was published for a 30 day public review and comment on August 

28, 2014. FRA did not receive any public comments related to FRA’s Section 4(f) de minimis impact 

analysis for these two properties. 

Finding of de minimis Impact

FRA finds that the Task 5 Project will not substantially impair the activities, features, and attributes that 

qualify the Louis Rasmussen Day Use Park for protection under Section 4(f). The majority of the impacts 

associated with the Project will be temporary and will occur during construction and the public’s use and 

enjoyment of the activities provided by the resource would not be substantially affected. In addition, the 

proposed Project includes plans for avoiding impacts to potential archaeological resources, transportation 

access to the Park, parking, and replacement of any Park facilities that are damaged as a result of the 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 26

construction activities. These measures were identified through consultation with the Port of Kalama, 

which has jurisdiction over the resource and provided its written concurrence with FRA’s analysis of 

impacts described above, by execution of a concurrence letter dated December 9, 2014. As a result, FRA 

finds that Task 5 will result in de minimis impacts to the Louis Rasmussen Day Use Park.

For the Task 6 project, at the Coweeman River Bridge it is noted that designs for the Coweeman River 

bridge modification and the second single-track rail bridge will not permanently affect the activities, 

features and attributes that qualify the Coweeman River Bridge for protection under Section 4(f). This 

determination is supported by consultation with DAHP. Base on FRA’s analysis of the impacts, and written 

concurrence by DAHP, FRA finds that the Task 6 project would have a de minimis impact on the Coweeman 

River Bridge. 
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 27

APPENDIX B: Environmental Commitments, Minimizations, and Best Management Practices for 

Task 5 and Task 6

The environmental commitments, BMPs, and minimization measures listed in the t able below 

include practices, techniques, methods, processes, and activities commonly accepted and used

throughout the construction and railroad industries that would be implemented as part of the Task 5

and Task 6 projects to facilitate compliance with applicable requirements and that provide an effective 

and practicable means of preventing or minimizing the environmental effects of an action. Also included are

additional commitments that FRA identified through the environmental review process and in consultation 

with other state and Federal resource agencies (e.g. Washington State Department of Archaeology and 

Historic Preservation and the U.S. Fish and Wildlife Service). WSDOT is responsible for implementing all 

measuresidentified in this Appendix B.
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 28

Appendix C: Environmental Assessment Comments and Responses
Kelso Martin’s Bluff Improvement Projects 

Task 5 and Task 6

Finding of No Significant Impact

March 2015

Page 29

Appendix D: Resource Agency Consultation